Dillon Williams v. State of Mississippi
2017 Miss. LEXIS 178
| Miss. | 2017Background
- Dillon Williams pleaded guilty to burglary and aggravated assault in Marshall County, Mississippi; indictment included a statutory sentencing enhancement under Miss. Code Ann. § 99-19-355 for a victim over 65.
- At the plea hearing Williams admitted the facts and the judge informed him that a guilty plea waives rights including the right to a jury trial and that the State would otherwise have to prove each indictment element to a jury.
- The trial court applied a 20-year enhancement to the aggravated-assault sentence under § 99-19-355 and imposed otherwise statutory sentences.
- Williams filed a post-conviction relief (PCR) petition arguing he was entitled to a jury sentencing proceeding for the enhancement and that his enhanced sentence was illegal.
- The trial court denied relief; the Court of Appeals affirmed, and the Mississippi Supreme Court granted certiorari and affirmed the denial of PCR.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Williams was entitled to a jury sentencing proceeding for the § 99-19-355 enhancement | Williams: statute requires a separate sentencing proceeding before the trial jury unless the defendant knowingly waives a jury for sentencing; he did not knowingly waive such a jury for the enhancement | State: Williams pleaded guilty and, during plea colloquy, knowingly and intelligently waived the right to a jury and admitted facts supporting the enhancement | Court: Waiver occurred during plea colloquy; guilty plea waived right to jury on enhancement, so no jury sentencing required |
| Whether the sentence (with the 20-year enhancement) is illegal | Williams: Judge imposed enhancement without a jury, making the enhancement portion illegal | State: Even if no waiver, the total sentence did not exceed statutory maximums and therefore is not illegal | Court: Sentence does not exceed statutory maximums; it is not an illegal sentence |
| Whether procedural bars to PCR are overcome by the fundamental-rights exception | Williams: Fundamental-rights exception to procedural bars should apply to claims of illegal sentence | State: Procedural statutory bars apply; petitioner waived jury by plea so claim lacks merit | Court: Did not rely on procedural bars because plea waived jury; concurrence questions application of fundamental-rights exception to legislatively codified PCR bars |
| Whether the plea colloquy sufficiently informed Williams he was waiving jury for the enhancement | Williams: Record does not show explicit waiver of a jury specifically for the enhancement sentencing | State: Plea colloquy expressly informed Williams that pleading guilty waives jury rights and reviewed the enhancement, so waiver was knowing | Court: Plea colloquy made Williams aware he waived jury rights as to the indictment including the enhancement; waiver was knowing and voluntary |
Key Cases Cited
- Joiner v. State, 61 So.3d 156 (Miss. 2011) (guilty plea waives multiple constitutional rights, including jury trial and requirement that State prove each element beyond a reasonable doubt)
- Foster v. State, 148 So.3d 1012 (Miss. 2014) (sentence is illegal only if it exceeds statutory maximum)
- Grayer v. State, 120 So.3d 964 (Miss. 2013) (defining limits of illegal-sentence review)
- Newell v. State, 308 So.2d 71 (Miss. 1975) (procedural rules are the province of the courts; Legislature cannot enact rules of procedure)
- Smith v. State, 477 So.2d 191 (Miss. 1985) (errors affecting fundamental rights may be exceptions to procedural bars)
- Grubb v. State, 584 So.2d 786 (Miss. 1991) (where statute required jury to fix certain penalties, judge’s imposition of a sentence that the jury alone could fix was plain error)
- Rowland v. State, 42 So.3d 503 (Miss. 2010) (application of fundamental-rights exception to procedural bars discussed)
- Rowland v. State, 98 So.3d 1032 (Miss. 2012) (clarifying scope of fundamental-rights exception to PCR procedural bars)